this Policy; and
the Australian Privacy Act 1988 (Cth) and other applicable privacy laws in the jurisdictions in which we operate, or in which our users are located (Privacy Laws).
If there is any inconsistency between the Privacy Laws and this Policy, the Privacy Laws will prevail to the extent of the inconsistency.
By creating an account with us, signing up to a newsletter, filling out a contact form, or otherwise engaging with us, you consent to us collecting, processing, using, and disclosing your personal information in accordance with this Policy.
You may withdraw your consent at any time by contacting us at firstname.lastname@example.org.
Personal information is information or an opinion of an individual whose identity is apparent or can be reasonably ascertained. As part of our business, we may collect personal information from you.
We collect a variety of personal information for the purposes of conducting and improving our business and our products and services.
We collect personal information in a number of ways, including:
through our educational and training services (in particular, in the enrolment process), our website located at www.one76.com and all of its subdomains (our Site), and various third party social media and messaging sites, channels, pages, groups and forums (collectively, our Services);
through our products and services;
through marketing research, including surveys and polls;
from competitions and other user participation events;
through any of our other business activities or events;
through a person seeking employment with us, having been employed by us, or being employed by us; and/or
by otherwise having some form of contact with a person, such as by personal contact, mail, telephone, email, video teleconferencing, Internet or other forms of telecommunication.
Personal information collected by us may include:
your contact details (including street address, postal address, email address, phone number, mobile phone number, and fax number);
your emergency contact information (including the name, relationship and phone number of your nominated emergency contact);
your country of birth, and your language ability (including whether English is your first language);
photo identification information (such as passport or driver licence number);
transactional information (including your method of payment);
nicknames, usernames and passwords that you use to access our Services or any of our products and services;
your reasons for using our Services or any of our other products and services;
your preferences and opinions relating to our Services or any of our other products and services;
any other information that you choose to send to us; and
usage data and logs, which may include information such as your Internet Protocol (IP) address, browser type, browser version, device type, make and model, clickstream/heatmap data, the pages of our Services that you visit, the features and functions of our Services you use, activities or actions you do while using our Services, the time and date of your visits to our Services, the time spent on any pages of our Services, and other log related information relating to your use of our Services.
Except as otherwise noted above, we endeavour to only collect personal information about you from you, where it is reasonable and practical to do so.
Generally, we use personal information for providing, evaluating, improving, personalising and developing our business, our Services, our other products and services, and to protect our users.
We may use personal information for:
improving our Services, our other products and services, and user satisfaction;
providing and delivering our Services and our other products and services to you;
providing support to you (including technical support) in relation to the use of our Services and our other products and services;
promoting and delivering our Services and our other products and services to organisations and individuals (which may or may not be associated with or connected to you);
our internal research and statistical purposes (including market segmentation and customer value analysis);
our internal business operations (including fulfilling any legal requirements); and
enabling us to forward to you other information or material which we believe may be of interest to you, or which you have indicated you may be interested in receiving.
We automatically gather information to monitor the use of our Services and our other products and services. Most of the data we collect is aggregated, and such aggregated information is effectively anonymous to us.
Sometimes you will be asked to confirm that you agree to a particular activity, or the collection of your personal information for a specific purpose.
We only disclose your personal information to third parties where directly related to the purposes for which the information was collected, including:
to external service providers (located in Australia and elsewhere), so that they can provide products and services in connection with the operation and improvement of our business;
to our commercial partners, affiliates, and sponsors (including for our own commercial benefit), including but not limited to other organisations and businesses within our group of organisations (if any);
as permitted under the Privacy Laws;
with your consent; and
if you would reasonably expect that your personal information would be passed to the person to whom the personal information is disclosed.
Information you make public
Certain services we provide and features on our Services are open to any other Service user to view, such as our blog (if any), community forum (if any) and certain aspects of your personal user profile (if any). Any information you create or post in these locations may be available and accessible to other users of our Services.
Our Services may also enable you to upload, post, transmit, display, perform or distribute content, information or other data, which may include your personal information. Any information that you choose to disclose by means of such features becomes public information.
We strongly urge you to exercise caution when deciding to disclose your personal information by such means. You agree to assume all responsibility for all personal information that you have made public.
Third party social media services
We may operate one of more forums, groups, chat rooms, or other services and facilities which are hosted on third party social media services and websites, including but not limited to, Facebook, Twitter, Instagram, Telegram, Slack, Flock, Reddit and LinkedIn.
Your use of, and participation in, such services and facilities are subject always to the terms of service, acceptable use policies, privacy policies, and other terms and conditions adopted by those third party social media services and websites.
Any information which you disclose on any third party social media services and websites is at your own risk and expense. We accept no liability or responsibility whatsoever in relation to the use, non-use or misuse of such third party social media services and websites by you or any other person.
We take reasonable steps to protect all personal information which we hold (including your personal information) from misuse, interference, loss, unauthorised access, modification or disclosure.
The precautionary steps we take to protect personal information may include:
adopting measures to protect our computer systems and networks used for storing, processing and transmitting personal information;
adoption of procedural and personnel measures for limiting access to personal information by our staff;
regularly reviewing our information collection, storage and processing practices;
secured encrypted servers, password protection for electronic files, multifactor authentication procedures, securing paper files in locked cabinets and physical access restrictions.
We also take steps to ensure that the personal information we collect is accurate, up-to-date and complete. These steps may include maintaining and updating personal information when it is apparent that updating is required, or we are otherwise advised by you that your personal information has changed.
Notwithstanding that we use our best endeavours to protect all personal information, we cannot completely guarantee the security of your personal information.
Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s or mobile device’s storage drive.
Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users or to access cookies.
Unlike cookies which are stored on the user’s computer or mobile device storage drive, web beacons are embedded invisibly on web pages (or in e-mail). Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns.
Like many sites, we use web beacons to collect information which is done in accordance with this Policy.
Overseas IT service providers
We may disclose personal information to outsourced information technology service providers, including cloud computing providers, data storage providers, and payment gateways/processors, based overseas primarily located in the United States of America and Europe. All data transferred outside Australia by us will be processed in accordance with this Policy.
We will take reasonable steps to ensure such overseas recipients do not breach the Australian Privacy Principles contained in the Australian Privacy Act 1988 (Cth), or are subject to laws or a scheme substantially similar to the Australian Privacy Principles.
Disclosure for analytics
We may use Google Analytics and other third party analytics software to track your usage of our Services. Google Analytics is a web analysis service provided by Google. Google utilises the data collected to track and examine the use of our Services, to prepare reports on its activities and share them with other Google services.
Consent to overseas disclosure
Other than as contemplated in this Policy, we will only disclose your personal information to an overseas recipient if:
you consent to the transfer; or
the disclosure of the information is required, authorised or permitted by or under an Australian law, other applicable law or a court/tribunal order.
We confirm that we have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third party websites, products or services whatsoever.
You should be aware that your ability to opt-out of a third party tool or platform will depend on the conditions governing your agreement with that third party.
Generally, all competitions run by us are hosted on our servers and are conducted, with respect to the collection and use of personal information, in accordance with this Policy.
Right to Access
You have a right, at all times, to obtain from confirmation from us as to whether or not your personal information is being processed by us, where such processing is occurring, and for what purpose.
We will provide you with access to your personal information held by us, unless:
giving access would be unlawful; or
denying access is required under any applicable law.
If you wish to access your personal information, please contact us at email@example.com.
Amendment of Personal Information
If you wish to amend personal information that we hold that is not editable through our Services, please contact us at firstname.lastname@example.org to request amendment. Depending upon the personal information you seek to access, you may be asked:
to put your request in writing with evidence to verify your identity; and/or
to provide further details to assist us in responding to your request in a timely manner.
We will respond to a request for access to personal information within a reasonable period after the request is made (or such other period required by law).
If we elect not to correct your information, we will within a reasonable time (or such other period required by law) notify you of the reason for our refusal, the mechanisms available for you to complain about our refusal and such other matters required by the applicable privacy legislation.
Right to be Forgotten
You have a right, at all times, to have us erase your personal information, and cease further dissemination of your personal information. If you wish to have your personal information deleted, please contact us at email@example.com and we will take all reasonable steps to delete it, unless we are required by law to keep it.
Right to Data Transfer
You have a right, at all times, to require us to provide a copy of your personal information to you, and have such personal information transferred to another party nominated by you. If you wish to have your personal transferred, please contact us at firstname.lastname@example.org and we will take all reasonable steps to do so, unless we are required by law to refuse your request.
We strive to ensure our compliance with this Policy and to regularly review our practices under it.
If at any time you have a complaint against us regarding our Policy, including a breach of the Privacy Laws, we invite you to contact us at email@example.com. All complaints made will be dealt with in confidence. We endeavour to respond within 30 days of receipt of a complaint with a resolution or proposed resolution of the issue raised.
Please note that you may also make a complaint to the Office of the Australian Information Commissioner (OAIC) about the handling of your personal information. Information on making a privacy complaint can be found on the OAIC website.
We reserve the right to vary this Policy from time to time without further notice to you. Any variations made will be updated on our Site. We will not reduce your rights under this Policy without using our best endeavours to first provide you with notice. It is your responsibility to check our Policy every now and again to ensure that you are aware of any changes made to it.
For any further information about this Policy please contact us at firstname.lastname@example.org.